U.S. Department of Energy

Energy Conservation Program for Consumer P

and Commercial and Industrial Equipme

Energy Conservation Standards Rulem

for Walk-In Coolers and Walk-In Free

Building Technologies Program

Office of Energy Efficiency and Renewable E

February 4, 2009

http://www1.eere.energy.gov/buildings/appliance_standards/comme

EERE-2008-BT-STD-0015 COMMENT 14
1 Introduction2 Rulemaking Overview3 Preliminary Analyses4 NOPR Analyses

Public Meeting Agenda

5 Final Rule Analyses6 Closing Remarks

EERE-2008-BT-STD-0015 COMMENT 14
Public Meeting Agenda

1 Introduction2 Rulemaking Overview3 Preliminary Analyses4 NOPR Analyses5 Final Rule Analyses6 Closing Remarks

EERE-2008-BT-STD-0015 COMMENT 14
Purpose of the Framework Public Meeting Present the procedural and analytical approaches the U.S. De

Energy (DOE or the Department) anticipates using to evaluate conservation standards for walk-in coolers and walk-in freezers or WICF)

 Encourage parties to submit data, information, and written com Inform parties and facilitate the rulemaking process

EERE-2008-BT-STD-0015 COMMENT 14
Background

 The Energy Independence and Security Act of 

2007 (EISA)

 Section 312(a): Defines the terms applicable to walk-in 

coolers and walk-in freezers.

 Section 312(b):

 Establishes prescriptive requirements mandated by 

Congress for walk-in coolers and walk-in freezers, applicable to all WICF equipment manufactured on or after January 1, 2009.

 Directs DOE to publish by rule, no later than 

January 1, 2012, energy conservation standards effective for equipment manufactured on or after 

three years from the date of publication.

 Section 312(c):

 Prescribes methods for determining the K factor 

and calculating the R value of insulation.

 Directs DOE to establish, by January 1, 2010, a 

test procedure to measure the energy use of walk-in coolers and walk-in freezers.

EERE-2008-BT-STD-0015 COMMENT 14
Background: Definitions EISA Section 312(a): Defines the terms ‘walk-in 

and ‘walk-in freezer’ to mean: “an enclosed storage space refrigerated to temperatures, respectively, above, and at or bedegrees Fahrenheit that can be walked into, antotal chilled storage area of less than 3,000 squfeet. The terms ‘walk-in cooler’ and ‘walk-in fredo not include products designed and marketed exclusively for medical, scientific, or research purposes.”

EERE-2008-BT-STD-0015 COMMENT 14
Background

 Federal Register - 74 FR 411 (January 6, 2009) and 

74 FR 1992 (January 14, 2009)

 Gives official public notice of the public meeting and 

availability of the Framework Document

 Initiates information and data collection process Encourages interested parties to submit comments

 Framework Document

 Explains issues, analyses, and the process that DOE 

is considering to develop energy conservation standards for walk-in coolers and walk-in freezers

 Solicits data and information, and invites comments

 A copy of the Framework Document is available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/wicf_framework_document.html

EERE-2008-BT-STD-0015 COMMENT 14
How to Submit Written Comments

 In all correspondence, please refer to the Walk-In Coolers and Wa

Rulemaking by

 Docket Number EERE-2008-BT-STD-0015, or

 Regulatory Identification Number (RIN) 1904-AB86.

 Email: wicf-2008-std-0015@ee.doe.gov Postal Mail: Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program, Mail Stop EE-2JWalk-In Coolers and Freezers Rulemaking, RIN 191000 Independence Avenue, SWWashington, DC 20585-0121

 Courier: Brenda Edwards

U.S. Department of EnergyBuilding Technologies ProgramWalk-In Coolers and Freezers Rulemaking, RIN 19950 L’Enfant Plaza, 6th FloorWashington, DC 20024

 Comment period closes February 12, 2009.

EERE-2008-BT-STD-0015 COMMENT 14
Rulemak

Public Meeting Agenda

1 Introduction2 Rulemaking Overview3 Preliminary Analyses4 NOPR Analyses5 Final Rule Analyses6 Closing Remarks

EERE-2008-BT-STD-0015 COMMENT 14
Rulemak

Stages of the Rulemaking Process

Federal Register notices

Framework

Document NOPR Final Rule

Opportunities for interested parties to participate

 Public meetings and oral comments Written comments on Federal Register notices an

Support Documents

Preliminary 

Analyses

EERE-2008-BT-STD-0015 COMMENT 14
Rulemak

Framework Document

Framework

Document NOPR Final Rule

Today

 Today’s public meeting covers the Framework Document for th

rulemaking.

 The Framework Document provides an overview of the rulema

process and encourages early participation by interested partie

 The Department encourages all interested parties to read the F

Document, available at: http://www.eere.energy.gov/buildings/appliance_standards/comwicf_framework_document.html

Preliminary 

Analyses

EERE-2008-BT-STD-0015 COMMENT 14
Rulemak

Preliminary Analyses

Energy Use and End-Use LoadCharacterization

Market and TechnologyAssessment

ScreeningAnalysis

EngineeringAnalysis

Markups forEquipmentPriceDetermination Life-Cycle

Cost andPayback Period Analysis

ShipmentsAnalysis

Framework

Document NOPR Final Rule Preliminary Analyses

EERE-2008-BT-STD-0015 COMMENT 14
Rulemak

Environmental Assessment

Life-Cycle Cost Subgroup Analysis

Manufacturer Impact Analysis

Utility Impact Analysis

Employment Impact Analysis

Analyses for Notice of Proposed Rulemaking (NOP

Revise

Preliminary

Analyses

Framework

Document NOPR Final Rule Preliminary Analyses

EERE-2008-BT-STD-0015 COMMENT 14
Rulemak

Framework

Document NOPR Final Rule

Analyses for Final Rule

DOJ 

Review

Preliminary 

Analyses

Revise NOPR Analyses

EERE-2008-BT-STD-0015 COMMENT 14
Test Procedures Section 312(c) of EISA states: “Not later than January 1, 

Secretary shall establish a test procedure to measure the use of walk-in coolers and walk-in freezers.”

 DOE is developing test procedures and rating temperatu

walk-in coolers and walk-in freezers covered under this rin a separate but concurrent rulemaking.

 DOE researched federal, state, and international standa

walk-ins and found no existing test procedures.

Tes

EERE-2008-BT-STD-0015 COMMENT 14
Item 2-1 The Department seeks feedback on appropriate test metrics annormalization factors for the walk-in coolers and walk-in freezers covered this rulemaking.

Rating Methods and Normalizing Factors

 The Department is considering several options for 

manufacturers to rate walk-in coolers and walk-in freezers, including:

 Test the equipment using a modified version of ANSI/ARI 

1200-2008: “Performance Rating of Commercial Refrigerated Display Merchandisers and Storage Cabinets.”

 Calculate the energy consumption using an Alternative 

Efficiency Determination Method (AEDM).

 Use some combination of these options.

 The Department is considering applying a normalizing 

factor to the test metric to accommodate equipment of different sizes.

 Gross Volume Floor Area

Tes

EERE-2008-BT-STD-0015 COMMENT 14
Rating Method 1: Use a Modified Version of ARI 12 Test the walk-in cooler or walk-in freezer at steady state within 

controlled test room, under the conditions specified in ASHRAE (“Method of Testing Commercial Refrigerators and Freezers”).

 Record test data for the walk-in cooler or walk-in freezer over a 

period to obtain the total energy consumption.

Advantages

 Test procedure already 

developed; requires some modification.

 Accurate.

Limitations

 Since many walk-in

custom-made, testieach one may be burdensome, expenor impractical.

Item 2-2 Walk-ins are excluded from the scope of ASHRAE 72. What mneed to address to be able to use this test method to rate walk-ins?

Tes

EERE-2008-BT-STD-0015 COMMENT 14
Rating Method 2: Develop an AEDM Examples of approaches include, but are not limited to:

 A calculation methodology; or  A computer simulation.

 The AEDM must be:

 Based on analytic evaluation of performance data of a walk-in; an Substantiated by testing a “significant sample” of walk-in units of t

and showing that the AEDM is accurate to a certain percentage. 

Advantages

 Easy to use for custom 

equipment because it does not require every unit to be tested.

Limitations

 May be inaccurate. May be difficult or 

impractical to devel

Item 2-3 What significant sample size should DOE use to substantiate a

Item 2-4 To what percentage should the AEDM be accurate?

Tes

EERE-2008-BT-STD-0015 COMMENT 14
AEDM: Example of Calculation Methodology Appr

+

Calculated Daily 

Energy Consumption

Other Electrical Com

Energy Consum

Determined by Spe

Compressor (CEC): 

Energy Consumption 

Determined by Heat Load

Electrical 

Component 

Heat Load

Non-Electrical 

Heat Load

 Conduction + Infiltration

 Lighting (LEC) + Evaporator and con

fans (FEC) +

 Defrost Heater (DEC Anti-sweat Heater ( Condensate Pan He

+

Tes

EERE-2008-BT-STD-0015 COMMENT 14
AEDM: Computer Simulation Approach A manufacturer may develop a computer model in order to calc

energy consumption of a walk-in.

 The computer model may simulate operation of the walk-in ove

time period.

 EISA states that “The test procedure may be based on comput

modeling, if the computer model or models have been verified results of laboratory tests on a significant sample of walk-in coowalk-in freezers.”

Tes

EERE-2008-BT-STD-0015 COMMENT 14
Prelimin

Public Meeting Agenda

1 Introduction2 Rulemaking Overview3 Preliminary Analyses4 NOPR Analyses5 Final Rule Analyses6 Closing Remarks

EERE-2008-BT-STD-0015 COMMENT 14
Preliminary Analyses

Market and Technolo

Framework

Document NOPR Final Rule

Energy Use and End-Use LoadCharacterization

Market and TechnologyAssessment

ScreeningAnalysis

EngineeringAnalysis

Markups forEquipmentPriceDetermination Life-Cycle

Cost andPayback Period Analysis

ShipmentsAnalysis

Preliminary 

Analyses

EERE-2008-BT-STD-0015 COMMENT 14
Relationship of Analyses

Market and Technology 

Assessment

Equipment Classes

Technology Options

Screening Analysis

Design Options

Baseline Models

Engineering Analysis

Market and Technolo

EERE-2008-BT-STD-0015 COMMENT 14
Purpose Characterize the walk-in cooler and walk-in freezer industry an

Market and Technolo

Method

 Identify and characterize manufacturers of walk-in coolers and 

freezers

 Estimate market shares and trends in the market Identify technologies that could be applied to walk-in coolers a

freezers

 Identify regulatory and non-regulatory initiatives intended to im

energy efficiency of the equipment covered under this rulemak

EERE-2008-BT-STD-0015 COMMENT 14
Overview of Walk-In Cooler and Walk-in Freezer Industry a

Market and Technolo

7%

62%

31%

CoolersFreezersCombination

Walk-Ins by Temperature Level

5

36%

25

39%

Food SalesFood ServiceOther

Walk-Ins by End-Use App

1 Inventory estimates from major walk-in manufacturers2 Manufacturer interviews; Freedonia, Energy Savings in Refrigerated Walk-in Boxes, DOE/EE-0170, 2004 3 Freedonia, Energy Savings in Refrigerated Walk-in Boxes, DOE/EE-0170, 2004 4 Manufacturer data5 Major manufacturers; Energy Savings Potential for Commercial Refrigeration Equipment, prepared for the U.S. Department of Ene

Arthur D. Little, June, 1996 (ADL ’96).

6 Commercial Building Energy Consumption Survey, Energy Information Administration, 2003; Major manufacturers

 Total Installed Base: 1,000,000 units1 Total Annual Sales: 40,000 units/year

2

 Total Market Value of 2008 Sales: $800,000,000

3

 Total Energy Consumption: 18.8 TWh

4

EERE-2008-BT-STD-0015 COMMENT 14
Characteristics of a Typical Walk-In Cooler and Walk

Annual Maintenance Cost $750-$1000 $500

Total Installed Cost $17,500 $8,90

Retail Equipment Cost $13,500 $7,90

10 10 Compressor Average Life (yr)

18 18 Insulated Box Average Life (yr)

Energy Use (kWh/yr) 14,600 15,60

Size (ft 140 80

2)

Cooling Capacity (Btu/h) 26,230 4,929

Cooler Freez

Sources: ADL ‘96; Analysis of Standard Options for Walk-in Coolers (Refrigerators) and Freezers, Pacific Gas and Elec2004; Energy Saving Incentives for High Efficiency Scroll Compressors in Walk-In Coolers, Emerson Climate Technolo2006; Food Marketing Institute Facts and Figures web site (www.fmi.org, June 2008), NCI Analysis, 2008; Distributor W

Market and Technolo

EERE-2008-BT-STD-0015 COMMENT 14
Request for Feedback

Item 3-1 DOE seeks information that would contribute to the marketassessment for walk-in coolers and freezers, including information on manufacturers, market shares, trends in the market, technological improand any other applicable information. Examples of the type of information by DOE, include, but are not limited to: a listing of walk-in cooler and freemanufacturers and their respective market shares, historical shipment daequipment class, equipment efficiency data by equipment class, etc. It is particularly important that DOE be aware of the major and small/niche manufacturers.Item 3-2 DOE seeks information on annual product shipments from 199

present (both domestic and imports), and the corresponding shipment-waverage efficiency of these shipments. Additionally, what units of measutypically used for annual shipments of this equipment (e.g., cases per yesquare-feet per year (floor-area-based), cubic-feet per year (refrigerated

based), etc)?

Market and Technolo

 Existing standards for the walk-in coolers and walk-in freezers covered 

rulemaking are design requirements. 

 These walk-in coolers and walk-in freezers have never before been the 

energy-use regulation at the Federal level. 

 Interested parties are encouraged to submit any available, applicable d

EERE-2008-BT-STD-0015 COMMENT 14
Possible Equipment Class Divisions to Consider

 Capacity: Small, Medium, or Large

 Small: Less than or equal to 1,000 ft

2

 Medium: Greater than 1,000 ft

2 and less than or equal to 2,000 ft

2

 Large: Greater than 2,000 ft

2

 Type: Self-contained or Remote Condensing

 Self-contained: The condensing unit is an integral part of the walk

freezer construction.

 Remote Condensing: The condensing unit is located elsewhere, p

equipment room.

 Location: Indoor or Outdoor

 Indoor: Fabricated within a building as part of that building.

 Outdoor: Constructed as a stand-alone structure or an extension o

building.

 Temperature: Cooler, Freezer, or Combination

 Cooler: Medium temperature  Freezer: Low temperature Combination: Has a medium temperature and a low temperature s

Market and Technolo

EERE-2008-BT-STD-0015 COMMENT 14
Examples of Equipment Classes Small, remote-condensing, indoor Large, self-contained, outdoor

 Small, self-contained, indo

freezer combination)

 Small, remote condensing

(walk-in display cooler)

Market and Technolo

EERE-2008-BT-STD-0015 COMMENT 14
Item 3-3 The Department requests feedback on the proposed classes fwalk-in coolers and freezers covered under this rulemaking, and thecriteria used in creating the classes.Item 3-4 What other equipment class divisions might be appropriate?

Item 3-5 What equipment classes, if any, can be combined for standard

purposes because of their similarities?Item 3-6 Can analyses for any one of these equipment classes be appliextrapolated to another equipment class?Item 3-7 Should all of these equipment classes be considered (e.g., do these equipment classes have few or no shipments)?

Market and Technolo

Request for Feedback

EERE-2008-BT-STD-0015 COMMENT 14
Baseline Units Will be selected once equipment classes are established Are selected for each equipment class, against which changes 

from energy conservation standards can be measured

 Represent typical characteristics of equipment in that class Are used in the engineering analysis and the life-cycle cost and 

period analysis

 Since no energy conservation standards exist, the Department 

surveying publicly-available product literature to establish basemodels.

 The Department also proposes to use information provided by 

parties in selecting appropriate baseline models.

Item 3-8 The Department seeks feedback on how to select a baseline m

each equipment class.Item 3-9 The Department seeks information on what particular componefeatures characterize the baseline model in each equipment class (e.g., dimensions, insulation, refrigerant type, compressors, evaporators, condexpansion devices, fans, motors, anti-condensate devices and controls, 

mechanisms and controls, lighting, etc.).

Market and Technolo

EERE-2008-BT-STD-0015 COMMENT 14
Initial Technology Choices:

remote lighting ballast location (i.e., outside the refrigerated space)higher-efficiency lighting ballasts (i.e. electronic rather than magnetic)non-electric anti-sweat heatingevaporator fan motor controllers (e.g. optimize duty cycle)higher-efficiency lighting (e.g., T8 fluorescent lamps, light-emitting diodes (LEDs))anti-sweat heater controls (e.g. dew point sensor)higher-efficiency evaporator fan motors (e.g. electronically commutated motors (ECM))higher-efficiency evaporator fan bladeseconomizer coolingexternal heat rejectionambient subcoolingfloating head pressureAll Equipment Types (continued on next slide)case insulation increases or improvementsdefrost mechanism (hot-gas defrost rather than electric defrost)

Scre

EERE-2008-BT-STD-0015 COMMENT 14
Item 3-10 What technologies or designs, if any, should DOE add or remthe above list?

Initial Technology Choices (continued):

higher-efficiency condenser fan bladesSelf-contained equipment onlycondenser fan motor controllershigher-efficiency condenser fan motors (e.g., electronically commutated motors (ECM))increased condenser surface area or efficiencyliquid-to-suction heat exchanger (LSHX) (i.e., subcool liquid refrigerant with suction line)higher-efficiency compressors (e.g., variable-speed compressors)

Scre

higher-efficiency expansion valves (e.g., dual-port thermostatic expansion valves (TXVs) a

expansion valves (EEVs))

increased evaporator surface area or efficiency to achieve lower case-evaporator temperadifferential (with a possible increase in fan energy)low pressure-differential evaporatorsAll Equipment Types (continued)Freezers onlydefrost cycle control (demand-based defrost rather than time-based defrost)

EERE-2008-BT-STD-0015 COMMENT 14
Preliminary Analyses

Scre

Framework

Document NOPR Final Rule

Energy Use and End-Use LoadCharacterization

Market and TechnologyAssessment

ScreeningAnalysis

EngineeringAnalysis

Markups forEquipmentPriceDetermination Life-Cycle

Cost andPayback Period Analysis

ShipmentsAnalysis

Preliminary 

Analyses

EERE-2008-BT-STD-0015 COMMENT 14
Purpose

Scre

Adverse impacts on health or safety

Adverse impacts on utility or availability to consumers

Practicability to manufacture, install and service

Technological feasibility

Method

 Each technology will be screened based on the following four c

 Screen out technology options that will not be considered in the

rulemaking for walk-in coolers and freezers

EERE-2008-BT-STD-0015 COMMENT 14
Preliminary Analyses

Engin

Framework

Document NOPR Final Rule

Energy Use and End-Use LoadCharacterization

Market and TechnologyAssessment

ScreeningAnalysis

EngineeringAnalysis

Markups forEquipmentPriceDetermination Life-Cycle

Cost andPayback Period Analysis

ShipmentsAnalysis

Preliminary 

Analyses

EERE-2008-BT-STD-0015 COMMENT 14
Method

Õ Define baseline units for each equipment class

baseline performance and cost data, apply maassumptions.

Õ Collect manufacturer production cost data to e

the cost of the core case.

Õ Identify applicable design options, collect man

cost data, qualify cost-energy consumption rel

Õ Incorporate interested parties’ feedback

Define Baseline Define Baseline

Finalize 

Analysis

Cost Model 

Development

Design Option 

Identification and 

Analysis

Engin

Purpose Characterize the relationship between manufacturer cost and 

consumption

EERE-2008-BT-STD-0015 COMMENT 14
Engin

Cost-Energy Consumption Curve Development

Energy Consumption

Manufacturing Cost

Baseline information is obtained for each equipment class

1

Cost data is plotted at energy consumption levels for each design option 

2

The design optionare re-ordered witthe most costefficient applied first

3

Energy Consumption

Manufacturing Cost

Energy Consumption

Manufacturing Cost

BASELINE

BASELINE

BASELINE

EERE-2008-BT-STD-0015 COMMENT 14
Request for Feedback

Engin

Item 5-1 DOE requests feedback on using a design-option approdetermine the relationship between manufacturer production cosenergy-efficiency levels for walk-in coolers and freezers. Item 5-2 DOE requests feedback on an appropriate representativcapacity (i.e., the most common or highest-volume capacity) for equipment class of walk-in coolers and freezers. Item 5-3 DOE seeks information on what particular components features (e.g., materials, dimensions, compressors, coils, expansdevices, fans, motors, controls, and panel construction charactercharacterize the baseline model in each equipment class. 

EERE-2008-BT-STD-0015 COMMENT 14
Manufacturing Cost Components

 Direct material Direct labor Factory overhead Depreciation

 Sales & marketing Research & development Interest Profit

Engin

Item 5-4 The Department seeks comment on the planned markup appro

proposed for developing estimates of manufacturer selling prices.

Full 

Production 

Cost

Markups 

(Non-Production Costs)

Manufac

+ = Selling 

 Examples of publicly available information:

 SEC 10-K reports Company annual reports Dun and Bradstreet reports Value Line industry statistics Standard and Poor’s composite industry statistics Ibbotson Associates reports

EERE-2008-BT-STD-0015 COMMENT 14
Item 5-5 Are there proprietary designs that the Department should cons

any of the equipment under consideration by this rulemaking? If so, how Department acquire the cost data necessary for evaluating these designsItem 5-6 Are there additional outside issues that the Department should in its analysis of walk-in coolers and freezers?

Engin

Proprietary Designs The Department will evaluate all design options that are comm

available or present in a working prototype, including proprieta

 Proprietary designs will only be considered if they do not prese

unique path to a given energy consumption level.

 The confidentiality of manufacturers will be maintained.

Outside Regulatory Changes Consider the effects to manufacturers of other regulatory chang

outside of the standards rulemaking process.

EERE-2008-BT-STD-0015 COMMENT 14
Preliminary Analyses

Markups for Equipment Price 

Framework

Document NOPR Final Rule

Energy Use and End-Use LoadCharacterization

Market and TechnologyAssessment

ScreeningAnalysis

EngineeringAnalysis

Markups forEquipmentPriceDetermination Life-Cycle

Cost andPayback Period Analysis

ShipmentsAnalysis

Preliminary 

Analyses

EERE-2008-BT-STD-0015 COMMENT 14
Markups for Equipment Price 

Purpose Develop overall distribution chain price markups from the manu

to the customer

 Establish the customer prices for both baseline equipment and 

equipment at higher standard levels

Manufacturer

Customer Customer

Manufact

Custom

Manufacturer

Distributor Distributor

Distribution Channel 1 Distribution Channel 2 Distribution Chann

Mech. Contractor

Distribution Channels

EERE-2008-BT-STD-0015 COMMENT 14
Markups for Equipment Price 

Two Types of Markups in Distribution Chain: Baseline and Incremental

 Markups relate consumer price to cost of goods sold (CGS).

 Baseline markups relate price to cost prior to a change in efficienc

 Baseline markups indicate a customer price that covers all of a dis

or contractor’s expenses plus profit.

 Incremental markups relate the incremental change in consum

the incremental change in CGS.

 Incremental markups cover only expenses that vary with CGS – in 

expenses that increase due to an increase in equipment efficiency

 Certain costs, such as direct labor costs (salaries, payroll, rental a

occupancy) do not vary with efficiency induced changes in CGS aconstant in the calculation of incremental markups.

Some costs may remain constant when CGS increases

EERE-2008-BT-STD-0015 COMMENT 14
Item 7-1 The Department requests information from interested parties o

proposed distribution paths for the walk-in coolers and freezers covered rulemaking. The Department also requests information on the relative frashipments expected for each path.Item 7-2 The Department requests feedback on if the overall markups f

walk-in coolers and freezers covered under this rulemaking for each path 

distribution chain.Item 7-3 The Department requests feedback on its proposal to use incre

distribution chain markups for the life cycle cost (LCC) analysis.Item 7-4 The Department seeks comment on other sources of relevant 

could be used to characterize markups for the walk-in coolers and freeze

Markups for Equipment Price 

Request for Feedback

EERE-2008-BT-STD-0015 COMMENT 14
Preliminary Analyses

Energy Use and End-Use Load C

Framework

Document

Preliminary 

Analyses NOPR Final Rule

Energy Use and End-Use LoadCharacterization

Market and TechnologyAssessment

ScreeningAnalysis

EngineeringAnalysis

Markups forEquipmentPriceDetermination Life-Cycle

Cost andPayback Period Analysis

ShipmentsAnalysis

EERE-2008-BT-STD-0015 COMMENT 14
 Develop energy use and peak electricity demand characteristic

buildings that use walk-in coolers and freezers.

 Provide the basis for the unit energy costs used in the Life-Cyc

Analysis.

Energy Use and End-Use Load C

Purpose

EERE-2008-BT-STD-0015 COMMENT 14
Energy Use and End-Use Load C

Method The Department is considering conducting a simplified analysis 

in coolers and freezers that does not address the impact of higefficiency design options on building space heating and cooling 

but is based on the engineering analysis tools the Department developing for walk-in coolers and freezers.

 Statistical data will be used to develop appropriate weights for 

resulting energy use data. These weights will be used to deveregional and national average net energy use figures as well ause distributions for specific equipment classes and efficiency 

EERE-2008-BT-STD-0015 COMMENT 14
Item 6-1 The Department seeks input on the relative merits of incorporawhole building space heating and cooling energy in its energy analysis ocoolers and freezers. If a whole building analysis is recommended, the 

Department seeks the reasons supporting this type of analysis as well as 

comments on what building types and analysis tool, and for which equipmclasses, such analysis should be considered.

Request for Feedback

Energy Use and End-Use Load C

EERE-2008-BT-STD-0015 COMMENT 14
Preliminary Analyses

Life-Cycle Cost and Payback P

Framework

Document

Preliminary 

Analyses NOPR Final Rule

Energy Use and End-Use LoadCharacterization

Market and TechnologyAssessment

ScreeningAnalysis

EngineeringAnalysis

Markups forEquipmentPriceDetermination Life-Cycle

Cost andPayback Period Analysis

ShipmentsAnalysis

EERE-2008-BT-STD-0015 COMMENT 14
 LCC equals customer price plus the sum of annual operating c

discounted to a particular base year

 Economic evaluation from the customer perspective Analysis Implemented in an Excel® spreadsheet

 Results are expressed as LCC difference (baseline minus stan

level)

 Simple payback (years) is also calculated and reported in this a

Combine 

Changes 

in Costs

LC

Life-Cycle Cost and Payback P

Method

First Cost

(Customer Price + 

Installation Cost)

Operating 

Expenses

Convert to 

Present 

Value

Purpose Assess the net life cycle cost (LCC) impacts of differing efficien

for walk-in coolers and freezers on the customer

EERE-2008-BT-STD-0015 COMMENT 14
LCC Flowchart

Life-Cycle Cost and Payback P

Baseline

Manufacturer

Price

Std-Level

Manufacturer

Price

Installation

Cost

From 

Engineering 

Analysis

(Price is a 

Function of 

Efficiency)

From Markups 

for Equipment 

Price 

Determination 

Analysis

Electricity

Prices

Repair Cost

Maintenance

Cost

Lifetime

Discount Rate

Electricity

Price Trend

From Energy 

Use & End Use 

Load 

Characterization 

Analysis 

(Energy Use & 

Load are a 

Function of 

Efficiency)

Energy

Consumption

Power

Demand

Distributor

Markup

Sales Tax

Mechanical

Contractor

Markup

Consumer

Price

Inte

O

Total Installed

Cost

Annual Energy

Expense

Annual

Operating

Expense

Lifetime

Operating

Expense

Payback

Period

EERE-2008-BT-STD-0015 COMMENT 14
Energy Prices Energy prices are necessary to convert the energy consumptio

equipment analyzed to energy costs. 

 DOE proposes to use regional average electricity and natural g

prices for its analysis of walk-in coolers and freezers as mandaEISA.

 DOE will use the Energy Information Administration (EIA) Annu

Outlook (AEO) as the default source of projections for future en

prices. 

 DOE will use the latest AEO forecasts for subsequent analyses

become available.

Life-Cycle Cost and Payback P

Item 8-1 The Department seeks comment on the proposed approaches 

estimating current and forecasted energy prices.

EERE-2008-BT-STD-0015 COMMENT 14
Discount Rates Discount rates are used to convert streams of annual operating 

expenses to present value in the LCC analysis.

 The Department will derive the LCC discount rates by estimatin

weighted average cost of capital (WACC) for companies that pwalk-in coolers and freezers. 

Life-Cycle Cost and Payback P

Item 8-2 The Department seeks comment on the proposed approaches 

estimating discount rates for customers purchasing the equipment coverthis rulemaking.Item 8-3 Given the relatively narrow commercial application of most of t

equipment covered under this rulemaking, which, if any, commercial secbeyond grocery stores and restaurants should be considered in the evaludiscount rates? In addition, do interested parties feel government purchaequipment are large enough to require that they be included in the evalu

discount rates?

EERE-2008-BT-STD-0015 COMMENT 14
Other LCC and PBP Analysis Inputs Installation costs Equipment lifetime Repair costs Maintenance costs

Life-Cycle Cost and Payback P

Item 8-4 The Department seeks feedback on whether changes in maint

repair, and installation costs will be negligible for equipment with lower econsumption. The Department also seeks feedback on whether changes maintenance, repair, and installation costs will change as a result of efficincreases and, if so, whether those changes are likely to be negligible. If costs are not likely to be negligible, please explain what those costs wouwhy this would likely be the case.Item 8-5 If it is not appropriate to assume that changes in maintenance

installation costs would be negligible for equipment with lower energy cothe Department seeks comment on appropriate methodologies for asseschanges to each of these costs.Item 8-6 The Department seeks comment on appropriate equipment life

the equipment covered in this rulemaking and the basis for these estimat

EERE-2008-BT-STD-0015 COMMENT 14
Preliminary Analyses

Ship

Framework

Document

Preliminary 

Analyses NOPR Final Rule

Energy Use and End-Use LoadCharacterization

Market and TechnologyAssessment

ScreeningAnalysis

EngineeringAnalysis

Markups forEquipmentPriceDetermination Life-Cycle

Cost andPayback Period Analysis

ShipmentsAnalysis

EERE-2008-BT-STD-0015 COMMENT 14
Purpose Project the rate of new equipment shipments under a proposed 

conservation standard

 Track the WICF equipment stock of equipment, by vintage, ove

frame of the standard

Ship

Method The life cycle of equipment is modeled as a “cradle to grave” p

which equipment moves from one state to another 

 New equipment is purchased and shipped to a building

 Equipment operates for some number of years in a building or atta

building

 Also, some equipment is “constructed on-site” The equipment is retired

 Data sources used include: product lifetimes, estimates of com

floor space, current product saturation rates by building type

 The shipments model is calibrated to historical shipments and 

saturation data

EERE-2008-BT-STD-0015 COMMENT 14
Item 9-1 The Department seeks information on representative saturatio

each equipment class covered under this rulemaking, as well as industry

data regarding relative growth in each equipment class.Item 9-2 As part of its preliminary manufacturer impact analysis, the Dewill seek input from manufacturers on the potential impact of new energy conservation standards on equipment shipments. Other interested partiewelcome to provide input. The Department also requests input on any m

programs that currently exist to promote the adoption of more-efficient Wequipment.

Request for Feedback

Ship

EERE-2008-BT-STD-0015 COMMENT 14
Preliminary Analyses

National I

Framework

Document

Preliminary 

Analyses NOPR Final Rule

Energy Use and End-Use LoadCharacterization

Market and TechnologyAssessment

ScreeningAnalysis

EngineeringAnalysis

Markups forEquipmentPriceDetermination Life-Cycle

Cost andPayback Period Analysis

ShipmentsAnalysis

EERE-2008-BT-STD-0015 COMMENT 14
 Uses a spreadsheet-based analysis tool Develops annual time series of energy and economic impacts Provides national summations of impacts for defined analysis  Utilizes the shipments model to estimate the total stock of wal

and freezers in service in any year

 Utilizes the LCC to estimate cost and energy use per unit in a Aggregates the costs and energy use, by vintage, for all years 

analysis period

 Reports estimates for energy use at the source of production 

source energy)

 Reports estimates for economic impact as change in NPV (in 

year dollars)

 Accounts for the time-value of money though use of defined d

Purpose

 Develop National Energy Savings (NES) and National Net Pre

(NPV) impact estimates for higher-efficiency standard levels.

Method

National I

EERE-2008-BT-STD-0015 COMMENT 14
Item 10-1 The Department seeks comment on its plan to develop NES 

spreadsheet models for estimating national impacts of energy conservatstandards for WICF equipment.

National I

Request for Feedback

EERE-2008-BT-STD-0015 COMMENT 14
NO

Public Meeting Agenda

1 Introduction2 Rulemaking Overview3 Preliminary Analyses4 NOPR Analyses5 Final Rule Analyses6 Closing Remarks

EERE-2008-BT-STD-0015 COMMENT 14
Revise Prelimin

Environmental Assessment

Life-Cycle Cost Subgroup Analysis

Manufacturer Impact Analysis

Utility Impact Analysis

Employment Impact Analysis

Analyses for Notice of Proposed Rulemaking

Revise

Preliminar

y

Analyses

RevisePreliminaryAnalyses

Framework

Document

Preliminary 

Analyses NOPR Final Rule

EERE-2008-BT-STD-0015 COMMENT 14
Life-Cycle Cost Subgr

Environmental Assessment

Life-Cycle Cost Subgroup Analysis

Manufacturer Impact Analysis

Utility Impact Analysis

Employment Impact Analysis

Analyses for Notice of Proposed Rulemaking

RevisePreliminaryAnalyses

Framework

Document

Preliminary 

Analyses NOPR Final Rule

EERE-2008-BT-STD-0015 COMMENT 14
Purpose Analyze the economic impacts of standards on customer subg

may be disproportionately impacted compared with the generapopulation

Item 11-1 The Department seeks input as to what customer subgroups 

Department should consider in the present rulemaking. Examples of possubgroups the Department could consider appropriate for walk-in coolers freezers include independent grocery stores and small convenience store

Life-Cycle Cost Subgr

 Extend the LCC analysis to examine the impacts for defined suMethod

EERE-2008-BT-STD-0015 COMMENT 14
Manufacturer Imp

Environmental Assessment

Life-Cycle Cost Subgroup Analysis

Manufacturer Impact Analysis

Utility Impact Analysis

Employment Impact Analysis

Analyses for Notice of Proposed Rulemaking

RevisePreliminaryAnalyses

Framework

Document NOPR Final Rule Preliminary Analyses

EERE-2008-BT-STD-0015 COMMENT 14
Manufacturer Imp

Purpose Assess the impacts of standards on manufacturers  Identify and estimate impacts on manufacturer subgroups that 

more severely impacted than the industry as a whole

 Examine the impact of cumulative regulatory burden on the ind

Method Analyze industry cash flow and net present value through use 

Government Regulatory Impact Model (GRIM)

 Interview manufacturers to refine inputs to the GRIM, develop 

analyses, and address qualitative issues

Output Industry Net Present Value impacts Subgroup Net Present Value impacts Other impacts

EERE-2008-BT-STD-0015 COMMENT 14
Manufacturer Imp

Methodology The MIA consists of three main phases: 

Industry profile

Develop preliminary GRIM

Develop interview guide

Interviews

& industrywide / 

subgroup

analyses

Aemcocubu

Phase 2 Phase 3

Preliminary MIA Interviews

Phase 1

Preliminary Analyses

EERE-2008-BT-STD-0015 COMMENT 14
Manufacturer Imp

Request for Feedback

Item 12-1 What procedures should DOE follow when scheduling intervie

requesting information?Item 12-2 DOE seeks comment on the establishment of manufacturer sfor walk-in coolers and freezers.Item 12-3 What regulations or pending regulations should DOE conside

analysis of cumulative regulatory burden?

EERE-2008-BT-STD-0015 COMMENT 14
Utility Imp

Environmental Assessment

Life-Cycle Cost Subgroup Analysis

Manufacturer Impact Analysis

Utility Impact Analysis

Employment Impact Analysis

Analyses for Notice of Proposed Rulemaking

Revise

Preliminary

Analyses

Framework

Document

Preliminary 

Analyses NOPR Final Rule

EERE-2008-BT-STD-0015 COMMENT 14
Purpose Assess the overall impacts on domestic energy supplies that w

from implementation of energy conservation standards. 

Utility Imp

 The Department proposes to use NEMS-BT, a variant of the N

(National Energy Modeling System) developed and used by DOtheir Annual Energy Outlook report, as the basis of the Utility ImAnalysis.

 Use the energy savings calculated from the NES spreadsheet 

reduce the sector electrical loads from the Commercial Building Module in NEMS-BT. 

 Energy savings translated to a reduction in the electrical dema

by the utility system over time resulting from the energy conserstandard.

Method

Item 13-1 The Department seeks input from interested parties on its propof NEMS-BT to conduct the utility impact analysis.

EERE-2008-BT-STD-0015 COMMENT 14
Employment Imp

Environmental Assessment

Life-Cycle Cost Subgroup Analysis

Manufacturer Impact Analysis

Utility Impact Analysis

Employment Impact Analysis

Analyses for Notice of Proposed Rulemaking

Revise

Preliminary

Analyses

Framework

Document

Preliminary 

Analyses NOPR Final Rule

EERE-2008-BT-STD-0015 COMMENT 14
Purpose Assess the overall impact on national employment from energy 

conservation standards.

 Include both direct and indirect employment impacts

 Direct employment impacts are estimated in the manufacturer imp

 Indirect employment impacts result from shifting customer expend

among goods and services ( “substitution effect”) and changing eq

and energy costs (“income effect”)

Employment Imp

Method The Department intends to use the IMSET (Impact of Sector E

Technologies) model for the evaluation of indirect employment impacts.

Item 14-1 The Department requests feedback on this approach to asseemployment impacts.

EERE-2008-BT-STD-0015 COMMENT 14
Environmental 

Environmental Assessment

Life-Cycle Cost Subgroup Analysis

Manufacturer Impact Analysis

Utility Impact Analysis

Employment Impact Analysis

Analyses for Notice of Proposed Rulemaking

Revise

Preliminary

Analyses

Framework

Document

Preliminary 

Analyses NOPR Final Rule

EERE-2008-BT-STD-0015 COMMENT 14
Purpose Estimate national environmental impacts from new energy con

standards for walk-in coolers and freezers covered under this r

Environmental 

 The Department intends to use the environmental impacts pred

the NEMS-BT modeling analysis used for the Utility Impact AnaImpacts calculated within NEMS include:

 Quantities of U.S. emissions of nitrogen oxides (NOx), mercury (H

(CO2) and from power plants.

 Direct environmental impacts from reduction of fossil fuel use at th

level.

 Any measurable impact from NEMS in terms of the trading price o

dioxide (SO2) in the utility sector and subsequent impact on SO2 e

 DOE will examine economic values associated with emissions 

reductions.

Method

EERE-2008-BT-STD-0015 COMMENT 14
Environmental 

Item 15-1 The Department seeks input from interested parties on its plan

NEMS-BT to conduct the environmental impact analysis on the equipment by this rulemaking. DOE is particularly interested in whether there are any approaches to the environmental assessment that it should consider and tadvantages and disadvantages for each of those approaches.Item 15-2 DOE invites comments on how to estimate such monetary valuassociated with emissions reductions or on any widely accepted values whmight be used in DOE’s analyses.Item 15-3 DOE seeks input on other environmental factors to consider in rulemaking.

Request for Feedback

EERE-2008-BT-STD-0015 COMMENT 14
Regulatory Imp

Environmental Assessment

Life-Cycle Cost Subgroup Analysis

Manufacturer Impact Analysis

Utility Impact Analysis

Employment Impact Analysis

Analyses for Notice of Proposed Rulemaking

Revise

Preliminary

Analyses

Framework

Document

Preliminary 

Analyses NOPR Final Rule

EERE-2008-BT-STD-0015 COMMENT 14
Purpose Explore the potential for non-regulatory approaches to supplan

augment energy conservation standards to improve efficiency equipment. 

Regulatory Imp

Item 16-1 The Department is unaware of any current non-regulatory initspecifically target the walk-in coolers and freezers covered under this rulAre interested parties aware of any such initiatives that should be examin

optional, non-regulatory approaches?Item 16-2 Are there specific subgroups of end-users whom the Departmshould consider in its review of potential adverse impacts from standards developed under this rulemaking?

Method

 Base the assessment on the actual impacts of any such initiat

date. DOE will consider information presented regarding the ithat any existing initiative might have in the future

EERE-2008-BT-STD-0015 COMMENT 14
Public Meeting Agenda

Final R

1 Introduction2 Rulemaking Overview3 Preliminary Analyses4 NOPR Analyses5 Final Rule Analyses6 Closing Remarks

EERE-2008-BT-STD-0015 COMMENT 14
Rulemak

Framework

Document NOPR Final Rule

Analyses for Final Rule

DOJ 

Review

Preliminary 

Analyses

Revise NOPR Analyses

EERE-2008-BT-STD-0015 COMMENT 14
Clos

Public Meeting Agenda

1 Introduction2 Rulemaking Overview3 Preliminary Analyses4 NOPR Analyses5 Final Rule Analyses6 Closing Remarks

EERE-2008-BT-STD-0015 COMMENT 14
Clos

Thank you. For more information... Website:

http://www.eere.energy.gov/buildings/appliance_standards/http://www1.eere.energy.gov/buildings/appliance_standards/commercial/wic

 Written comments

 The comment period will be open until February 12, 2009.

Please reference the rulemaking docket number EERE-2008-BT-STD-0015 

1904-AB86, in all correspondence.

Email: wicf-2008-std-0015@ee.doe.gov

Mail: Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program, Mail stop EE-2JFramework for Walk-In Coolers and Walk-In Freezers, RIN 1904-AB861000 Independence Avenue, SWWashington DC, 20585-0121

Courier: Brenda Edwards

U.S. Department of EnergyBuilding Technologies ProgramWalk-In Coolers and Freezers Rulemaking, RIN 1904-AB86950 L’Enfant Plaza, 6th FloorWashington, DC 20024 

 Contact:

 Charles Llenza, telephone: (202) 586-2192, or e-mail: charles.llenza@ee.

EERE-2008-BT-STD-0015 COMMENT 14
BACKUP SLIDES

EERE-2008-BT-STD-0015 COMMENT 14
Manufacturer Imp

Legislative Requirements EPCA

 DOE must consider the economic impact of standards on manufac DOE must consider the impacts of any lessening of competition in 

industry.

 The Process Rule

 “Procedures, Interpretations and Policies for Consideration of New 

Energy Conservation Standards for Consumer Products” (10 CFR Subpart C, Appendix A). 

 Contains principles for the analysis of regulatory impacts on manu

 2006 Report to Congress

 DOE announced changes to the format of the MIA (as required by 

of EPACT 2005).

 DOE will collect, evaluate, and report preliminary manufacturer im

analysis information in the Preliminary Analyses phase.

 This information includes the anticipated conversion capital expen

efficiency level and the anticipated impacts on jobs.

EERE-2008-BT-STD-0015 COMMENT 14
Background: Performance Standards EISA Section 312(b): Directs DOE to issue energy conse

standards.

A. “The Secretary shall publish performance-based standards 

in coolers and walk-in freezers that achieve the maximum improvement in energy that the Secretary determines is technologically feasible and economically justified” by Jan2012.

B. The standards shall apply to walk-ins that are manufacture

beginning on the date that is 3 years after the final rule is published. If the Secretary determines, by rule, that a 3-yis inadequate, the Secretary may establish an effective datins manufactured beginning on the date that is not more thafter the date of publication of a final rule.

EERE-2008-BT-STD-0015 COMMENT 14
Background: Test Procedures EISA Section 312(c): Details requirements for test proce

A. For the purpose of test procedures for walk-in coolers and 

freezers:

i. The R value shall be the 1/K factor multiplied by the th

the panel.

ii. The K factor shall be based on ASTM test procedure 

2004.

iii. For calculating the R value for freezers, the K factor o

at 20 °F (average foam temperature) shall be used.

iv. For calculating the R value for coolers, the K factor of 

at 55 °F (average foam temperature) shall be used.;

B. Development of a test procedure:

i. Not later than January 1, 2010, the Secretary shall es

test procedure to measure the energy use of walk-in cwalk-in freezers.

ii. The test procedure may be based on computer mode

computer model or models have been verified using tof laboratory tests on a significant sample of walk-in cwalk-in freezers.

EERE-2008-BT-STD-0015 COMMENT 14
Background: Design Standards: EISA Section 312 EPCA Section 342(f)(1): “In general.— ...each walk-in cooler or walk-i

manufactured on or after January 1, 2009, shall—

A. “have automatic door closers that firmly close all walk-in doors that have be

within one inch of full closure, except that this subparagraph shall not apply 

than 3 feet 9 inches or taller than 7 feet;

B. “have strip doors, spring hinged doors, or other method of minimizing infiltra

are open;

C. “contain wall, ceiling and door insulation of at least R-25 for coolers and R-

except that this subparagraph shall not apply to glazed portions of doors nomembers;

D. “contain floor insulation of at least R-28 for freezers;

E. “for evaporator fan motors of under 1 horsepower and less than 460 volts, u

i. “electronically commutated motors (brushless direct current motors); ii. “3-phase motors;

F. “for condenser fan motors of under 1 horsepower, use—

i. “electronically commutated motors;ii. “permanent split capacitor-type motors; or iii. “3-phase motors; and

G. For all interior lights, use light sources with an efficacy of 40 lumens per wa

including ballast losses (if any), except that light sources with an efficacy of watt or less, including ballast losses (if any), may be used in conjunction wi

device that turns off the lights within 15 minutes of when the walk-in cooler 

freezer is not occupied by people.”

EERE-2008-BT-STD-0015 COMMENT 14
Background: Design Standards: EISA Section 312 EPCA Section 342(f)(1): “Electronically commutated motors.—

A. “In general.— The requirements of paragraph (1)(E)(i) for electron

commutated motors shall take effect January 1, 2009, unless, prio

date, the Secretary determines that such motors are only availabl

manufacturer.

B. “Other types of motors.— In carrying out paragraph (1)(E)(i) and 

subparagraph (A), the Secretary may allow other types of motors Secretary determines that, on average, those other motors use no energy in evaporator fan applications than electronically commuta

C. “Maximum energy consumption level.— The secretary shall estab

maximum energy consumption level under subparagraph (B) not l

January 1, 2010. 

EERE-2008-BT-STD-0015 COMMENT 14
Background: Design Standards: EISA Section 312 EPCA Section 342(f)(1): “Additional specifications.— Each wa

and walk-in freezer with transparent reach-in doors manufactuafter January 1, 2009, shall also meet the following specificatio

A. “Transparent reach-in doors for walk-in freezers and windows in w

freezer doors shall be of triple-pane glass with either heat-reflectivglass or gas fill.

B. “Transparent reach-in doors for walk-in coolers and windows in w

doors shall be:

i. “double-pane glass with heat-reflective treated glass and gas ii. “triple-pane glass with either heat-reflective treated glass or 

C. “If the appliance has an antisweat heater without antisweat heate

the appliance shall have a total door rail, glass, and frame heater of not more than 7.1 watts per square foot of door opening (for fre3.0 watts per square foot of door opening (for coolers).

D. “If the appliance has an antisweat heater with antisweat heater co

the total door rail, glass, and frame heater power draw is more thaper square foot of door opening (for freezers) and 3.0 watts per sdoor opening (for coolers), the antisweat heater controls shall redenergy use of the antisweat heater in a quantity corresponding to humidity in the air outside the door or to the condensation on the pane.”

EERE-2008-BT-STD-0015 COMMENT 14